Business and Regulatory Impact Assessment for Scotland's Trafficking and Exploitation Strategy 2025

Section 2: Engagement and information gathering

Engagement approach

The Strategy has been developed through collaboration with key stakeholders. A broad range of engagement forums has shaped the work, from statutory agencies and local authorities to specialist third sector organisations, survivor networks, and industry representatives. Following publication of the Strategy, officials undertook targeted engagement with business stakeholders to inform this final BRIA and the accompanying Delivery Plan.

Internal SG engagement/ engagement with wider Public Sector

Engagement internally has involved a range of key Policy areas. Including, but not limited to, Serious and Organised Crime, Violence against Women and Girls, Child Protection, and Health and Social Care. COSLA, Police Scotland, and NHS Scotland have been key partners as well as wider organisations such as the Crown Office and Procurator Fiscal Service, who have contributed through working groups and direct engagement. When considering the revised strategy, policy areas with mutual interests and strong alignment, including in the business policy areas, have been included and they will continue to be engaged as it is implemented. During the implementation of the Strategy we plan to further engage with Scottish Government policy groups for the sectors which have elevated vulnerability to trafficking and exploitation, such as fisheries, construction, social care and hospitality amongst others.

We have not engaged with the Regulatory Review Group nor with DITI as no new regulations were made and investment interests are unaffected by the Strategy.

UK/ Devolved Administrations

The Scottish Government has worked regularly with the UK Government and other Devolved Administrations. The Scottish Government is a member of the Modern Slavery Engagement Forum, hosted by the Home Office. Recently we have also contributed to the Forced Labour Forum which has led to refreshed Statutory Guidance about responsibilities under Section 54 of the Modern Slavery Act^[2]. This has supported policy development, facilitated cross-border understanding, and enabled joint working.

Wider Public Sector

We have engaged with COSLA who also form part of our Action Area groups and therefore have regular information exchange and awareness of developments in relation to trafficking and exploitation. We have not engaged with other regulatory bodies nor with enterprise agencies as this was deemed unnecessary.

International

No direct engagement with overseas governments was undertaken specifically for the purposes of this BRIA. Given that the Strategy introduces no new regulatory requirements affecting international trade, this was considered proportionate.

Business / Third Sector engagement

Officials attended a roundtable with Scotland Against Modern Slavery^[3], a business-led partnership of over 80 organisations from sectors including food and drink, agriculture, construction, logistics, manufacturing, energy, transport, higher education and social care. SAMS works to raise awareness of trafficking and exploitation, promote ethical recruitment and employment practices, share intelligence and good practice, and support survivors into sustainable employment amongst businesses in Scotland.

The roundtable provided an opportunity to present and discuss the Strategy, gather feedback from a broad range of businesses, and explore any potential impacts for businesses operating across Scotland. Participating organisations within SAMS includes major employers such as Scottish Water, SSE, Mowi, Baxters, Walkers, Malcolm Group, Highland Spring, Forth Ports, the University of Glasgow, and a range of businesses representing sectors considered at greater risk of labour exploitation.

In addition to direct engagement with SAMS, officials engaged with Business Representative Organisations (BROs) through the Scottish Government's Strategic Relationships and Communications Directorate. This provided a channel to test the Strategy with a wide range of businesses representatives.

Stakeholders did not identify concerns or adverse impacts arising from the refreshed strategy during engagement. The Scottish Government will, however, continue to engage with businesses and representative organisations throughout implementation to gather feedback, monitor any emerging impacts, and ensure that delivery remains informed by stakeholder experience.

Public consultation

In September 2023 we published a review^[4] of the existing Trafficking and Exploitation Strategy, published in 2017, following extensive engagement with stakeholders including survivors of trafficking, third sector organisations, service providers, COSLA, Public Health Scotland, the Independent Anti-Slavery Commissioner, academics and researchers, Police Scotland and other law enforcement organisations.

The review concluded that some specific areas required attention, such as the requirement for a more strategic approach to awareness raising and training opportunities; a greater emphasis on evidence, data collection and sharing and an increased focus on prevention. Stakeholders also remarked that a number of the overarching objectives within the Strategy remain core aspirations and continue to provide important guidance. As such, a new Strategy would improve the interconnectedness of work under each Action Area, improving the flow of information sharing, cross-group working and learning.

A number of the goals within the Strategy, as set in 2017, were considered to be no longer relevant, either as a result of progress or as a result of evolving priorities. As such, it was concluded that the Key Performance Indicators warranted a refresh to bring them in line with policy and operational developments.

From the extensive engagement undertaken, it was clear that stakeholders’ unanimous view was that a refresh of the Strategy should be prioritised and this would allow us to reflect the changing landscape and evolving workstreams in our attempts to combat human trafficking.

We then embarked on a consultation process, involving in-person workshops, online discussions and written feedback on draft versions of the Strategy with our stakeholders, culminating in the final version of the Strategy.

Other stakeholders and actions

The Strategy is also informed by a series of evidence reviews carried out by the Scottish Government’s Justice Analytical Services (JAS), exploring current understanding of prevention strategies and interventions in relation to human trafficking and exploitation in the United Kingdom (UK) and other existing forms of research and evidence.